Scenario

Prepare for the December 2026 ADM deadline.

Aicura supports the work of cataloguing your AI systems and drafting a privacy policy that addresses APP 1.7 to 1.9.

What's required

The Privacy and Other Legislation Amendment Act 2024 added new transparency obligations to APP 1 of the Privacy Act, all of which commence on 10 December 2026. APP 1.7 requires APP entities that make significant decisions about individuals using AI or other automated processes to disclose that fact in their privacy policy. APP 1.8 requires disclosure of the kinds of personal information used in those decisions. APP 1.9 requires disclosure of the kinds of decisions being made.

From the commencement date every APP entity needs an updated privacy policy that addresses these obligations, and the OAIC is preparing for compliance review activity from the same day. The longer reading of what each obligation requires sits on the ADM framework page.

Catalogue your AI systems

The first time you sign in, the register is empty and the deadline counter is already counting down. You start by adding the systems your organisation actually uses, and Aicura ships with a prefill catalogue of well-known products, so vendor entries usually mean selecting from the catalogue rather than typing into a blank form. For systems built in-house, the Helper PDF lets you collect the technical fields offline from your data science team without making them learn the app, and what comes back gets uploaded straight into the register.


After publication, the work is no longer about a deadline. The register, your privacy policy, and the history of guidance Aicura produced along the way live in the same place and stay connected as the work continues. When questions come from the OAIC, your audit committee, or your board, your team has somewhere concrete to draw on.


Frequently asked questions

Do I have to disclose AI in my privacy policy?

Yes, where your organisation uses a computer program to make, or substantially help make, a decision that significantly affects a person. From 10 December 2026 Australian Privacy Principle 1.7 to 1.9 require you to set this out inside the privacy policy itself, naming the kinds of decisions made and the kinds of personal information used. The date is the trigger and not the finish, so you keep the disclosure true as you add and change automated-decision systems.

What counts as an automated decision?

An automated decision is one a computer program makes wholly or substantially by automated means, where the outcome significantly affects a person's rights or interests. This covers both fully-automated decisions, where no person reviews the result, and substantially-assisted ones, where a system does the deciding work and a person signs off. A person clicking approve at the end does not move a decision out of scope if the system shaped the outcome.

Does a human reviewing the decision take it out of scope?

Not on its own. The test in APP 1.7 is whether the decision is made wholly or substantially by automated means, so a decision where a system does the substantive work and a person approves the result is still in scope. The line that matters is whether the person adds independent judgment or rubber-stamps the system's output.

What do I need in place by 10 December 2026, and after?

By 10 December 2026 your privacy policy needs a disclosure for each automated decision that significantly affects a person, set out in the policy APP 1 governs. After the date that disclosure has to stay accurate, because a statement that was true in December goes wrong the moment a new system ships or an old one is retired. The work is ongoing, so you keep the policy reconciled to the systems your organisation actually runs.

Keep the disclosure true after December

The 10 December 2026 deadline is the reason to start now, and keeping the disclosure true afterwards is the reason to stay. Every time your organisation adds or changes an automated-decision system, the privacy policy has to keep up, or the disclosure stops matching what you actually run. Aicura keeps the AI Register and the privacy policy reconciled as that happens, so the disclosure stays current long after the deadline passes. If you would rather see the work first, the guided tour walks through the register, the policy review and what it surfaces without asking for an account.